How States Are Responding to New SNAP Requirements

How States Are Responding to New SNAP Requirements

The One Big Beautiful Bill Act expands the food program's work requirements, restricts noncitizen eligibility and imposes new reporting requirements.

Because of new restrictions on SNAP eligibility for noncitizens, many lawfully present immigrants may already have lost their benefits. (Jet City Image/Getty Images)

The federal Supplemental Nutrition Assistance Program, formerly known as food stamps, aims to mitigate food insecurity and support low-income individuals and families. Here is a look at recent changes to the program resulting from the enactment last year of President Donald Trump's domestic policy law, the One Big Beautiful Bill Act, and how states are responding.

SNAP Changes at a Glance

• Individuals newly subject to SNAP work requirements may begin to lose benefits.
• The USDA's Food and Nutrition Service, which oversees SNAP, has updated its noncitizen eligibility guidance.
• NCSL and other national organizations are advocating for a time-limited extension of the cost-shifting provisions.
• States are working to reduce payment error rates and streamline SNAP processes.

SNAP Landscape: Fall 2025-Winter 2026

Program changes: The OBBBA expands SNAP work requirements, restricts noncitizen eligibility and changes the amount of aid eligible households can receive-all of which took effect immediately after the bill was signed, July 4, 2025. The law shifts some SNAP costs to the states by creating a new state matching requirement for benefits and increasing the state share of administrative costs. Historically, the federal government has covered 100% of benefit costs and 50% of administrative expenses; that will change once the administrative cost shift takes effect on Oct. 1 this year, followed by the benefit cost shift on Oct. 1, 2027. The law shifts 5%-15% of benefit costs to states with payment error rates above 6% and requires states to pay 75% of the program's administrative costs. Payment error rate is the average of overpayments and underpayments that a state makes to enrollees.

Implementation challenges: Further challenging state implementation was the federal government shutdown in October 2025, which disrupted both federal and state SNAP operations and delayed guidance from the Agriculture Department's Food and Nutrition Service, which administers the program. Guidance regarding work requirements and noncitizen eligibility was not released until October and December respectively.

Payment error rates: States are engaged in various stages of system upgrades, policy updates, staff training and recruitment, and public outreach. The speed of implementation directly influences each state's payment error rate, which in turn impacts the percentage of a state's share of program benefit costs. While many states implemented the new eligibility requirements before the end of the hold-harmless period on Nov. 1-when payment errors began to accrue-others are still in the early stages of compliance, leading to ongoing accrual of payment errors.

The importance of full implementation cannot be overstated. Based on the USDA's fiscal year 2024 payment error data, benefit cost shifts for states with rates above 6% range from $5.5 million in North Dakota and $37 million in Hawaii to $991 million in Florida and $1.8 billion in California. This is on top of an average $67 million increase per state for administrative costs.

Coverage Losses in Effect

Noncitizens: Because the OBBBA's restrictions on noncitizen SNAP eligibility went into effect on July 4, 2025, many lawfully present immigrants who are no longer eligible for the program may already have lost their benefits in states that have implemented the law's provisions. The hold-harmless period for implementation of these provisions has since been extended until April 9, 2026, for 21 states as a result of a lawsuit filed in November 2025. The suit challenged the legality of the USDA's initial guidance on noncitizen eligibility, which stated that immigrants arriving in the U.S. legally as refugees, asylees or as part of certain other groups were permanently barred from SNAP eligibility and that certain humanitarian categories of immigrants were subject to a five-year waiting period, regardless of status. The USDA subsequently clarified that immigrants whose legal status changes to lawful permanent resident are eligible for SNAP, immediately in some instances, provided other statutory conditions are satisfied.

People newly subject to work requirements: States that implemented the expanded work requirements on or before Nov. 1 have passed the first three-month period after which individuals newly subject to work requirements-people age 55-64, caregivers of children age 14 and older, veterans, people experiencing homelessness and people 24 and younger transitioning out of foster care-will lose coverage if they're unable to demonstrate that they have worked 80 hours per month or engaged in another approved activity.

State Implications and Opportunities

As they move to implement the OBBBA's changes, states are evaluating staffing levels and internal procedures used to determine SNAP eligibility and benefit amounts. Because SNAP payment error rates can affect states' costs under the new federal framework, administrative performance and system readiness have become immediate priorities.

Recent legislative activity reflects this urgency. States are considering proposals to fund system upgrades, expand quality-control capacity and strengthen verification and reporting practices tied to payment accuracy and compliance. Approaches differ by state, but many bills center on ensuring that core administrative functions-eligibility processing, verification and oversight-are positioned to operate effectively under the new rules.

Recent state actions include:

Investments in SNAP systems and administration: Several states have introduced or enacted legislation providing funds to support SNAP administration. These measures target eligibility-system modernization, quality-control capacity and fiscal planning to address payment-accuracy requirements and potential funding disruptions.

• California AB 146 (2025, pending) would appropriate funding for automation and system upgrades intended to reduce payment errors and facilitate the OBBBA's changes.
• Maine HB 1437 (2026, pending) would create a contingency fund to maintain SNAP benefits during potential federal funding disruptions.
• New Hampshire HB 1750 (2026, pending) would authorize supplemental appropriations to address shortfalls associated with federal cost-share changes to SNAP.
• Ohio HB 434 (2025, enacted) appropriated funding to update the state's benefits system to help reduce payment error rates.
• Washington HB 2289/SB 5998 (2026, pending) would provide additional funding to expand quality-control staffing and contractor support to improve eligibility determination and verification.

Eligibility procedures and verification: States are considering changes to SNAP eligibility and verification procedures. Proposals address documentation standards, data-sharing practices, recertification timelines and compliance pathways tied to participation rules.

• Alabama SB 61 (2026, pending) would establish monthly and quarterly reviews of federal and state data to reassess eligibility, restrict categorical eligibility and define SNAP certification periods according to household characteristics.
• Georgia HB 947 (2026, pending) would require citizenship verification, compliance with federal work requirements and annual recertification beginning in 2027.
• New Hampshire HB 1797/SB 615 (2026, pending) would require data sharing agreements among state agencies to verify eligibility; includes changes to work requirements.
• New Jersey AB 6115/SB 4971 (2026, pending) would direct the state's Department of Human Services to support volunteerism as a compliance option for certain eligibility-related SNAP requirements.

Oversight and payment accuracy: State bills to strengthen SNAP payment accuracy and oversight include error-rate targets, additional reporting requirements and directives to develop plans to identify and reduce incorrect eligibility or benefit determinations.

• Arizona HB 2206 (2026, pending) would set a 3% error-rate target by 2030, require annual progress reporting and outline corrective actions if targets are not met.
• Maine HB 1437 (2026, pending) would establish an electronic system to identify and address erroneous eligibility determinations.
• Oklahoma SB 1310 (2026, pending) would tie SNAP administrative leaders' salaries to the state's payment error rate, reducing salaries when errors exceed the federal threshold and providing bonuses when accuracy improves.
• Rhode Island HB 5076 (2025, enacted) requires creation of a plan to reduce the state's error rate below 6% and mandates monthly progress updates.

NCSL Advocacy

In response to the overlapping challenges of the OBBBA's changes, the government shutdown and the delays in federal guidance, NCSL joined other state and local government organizations in asking Congress to include in the recent appropriations package a delay of the cost-sharing provisions until fiscal year 2030. The request, designed to support state efforts to maintain program integrity, was elevated at a congressional briefing in early January. Although the delay was not included in the final legislation, coalition efforts to educate Congress about state initiatives to ensure accuracy and accountability in their SNAP programs continue. NCSL again elevated the issue in response to 2026 Farm Bill negotiations and encourages members to regularly update their congressional representatives on progress and/or challenges encountered during SNAP implementation.

Looking Ahead

State legislatures have much work to do to meet the requirements of the new federal framework. Although the changes introduce notable operational and fiscal challenges, they also present opportunities for states to update systems, refine verification processes and improve data practices that affect accuracy and efficiency. Investments in technology, workforce development and cross-agency coordination could help states not only implement the new administrative requirements but also improve service delivery for households receiving SNAP benefits.

In the months ahead, NCSL will monitor state efforts to balance the OBBBA's compliance requirements with sustainable administrative practices, and report on any federal developments.

Lauren Kallins is a senior legislative director in NCSL's State-Federal Affairs Division.

Ashton Thompson is a policy associate in NCSL's Children and Families Program.